Executive Summary
In comments to the Department of Health and Human Services, NHeLP explains that the ARHOME project raises serious legal concerns. The application does not include a sufficient level of detail to allow for meaningful comment on several features of the project. What is clear from the application is that Arkansas is seeking permission to implement a number of policies – imposing premiums, waiving retroactive coverage, and restricting access to services through various mechanisms – that conflict with the core objective of the Medicaid Act and serve no experimental purpose.
